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85 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …her petitioners' gross income for the subject years includes rental income of $21,113, $11,460, $13,428, $33,994, $57,166, and $22,272, respectively. We hold that it does. We also decide whether petitioners may deduct
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  3. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989★ strong match
    …Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. H. Rept. 1447 at 428, 87th Cong., 2d Sess. at 428 (1962), 1962-3 C.B. 405, 423; S. Rept. 1881, 87th Cong. 2d Sess. at 169 (1962), 1962-3 C.B. 707, 731. Cf. Sanford v. Commissioner, 50 T.C. 823, 826 (1968), affd. per curiam 412 F. 2d 201 …
  4. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    …r affected homeworker Minor Substantial Repeated, intentional or knowing Recordkeeping $21-214 $214-428 $428-1,071 Monetary violations 21-214 214-428 Employment of homeworkers without a certificate 214-428 428-1,071 Other violations of statutes, regulations or employer assurances 21-214 214-428 428-1,071
  5. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …ule C, Profit and Loss From Business, of his 1995 tax return, petitioner reported deductions of $70,428.52 from his automobile drag racing activity named Emerson Racing Enterprises. Petitioner reported no income from this activity, resulting in a $70,428.52 loss. Related to this loss in 1995, petitioner carried back a …
  6. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  7. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  8. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015
    …ng the magistrate judge's findihgs and recommendation. On December 7, 2009, FHB issued a check for $428,103.63 from petitioner's IRA to the clerk of the District Court. Additionally, on December 8, 2009, FHB i sued a check for $89,343.98 from petitioner's IRA to UPW. Thereafter, FHB issued a Form 1099-R, Distributions …
  9. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    … § 726.302(c)(2)(i) table $139 $143. § 726.302(c)(2)(i) table 278 285. § 726.302(c)(2)(i) table 417 428. § 726.302(c)(2)(i) table 555 569. § 726.302(c)(4) January 2, 2018 January 23, 2019. § 726.302(c)(4) $139 $143. § 726.302(c)(5) January 2, 2018 January 23, 2019. § 726.302(c)(5) $417 $428. § 726.302(c)(6) January 2, …
  10. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  11. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …Apart 33,000 33,000 550.00 16,280 Sub-Total 17,384,942 8,708,971 145,150 4,296,426 Uniform Glossary 428,232 428,232 7,137 211,261 Notice of Modification 342,585 171,293 2,855 84,504 Individual Market: SBC with Coverage Examples 21,784,217 6,535,265 108,921 3,224,064 Uniform Glossary 762,448 762,448 12,707 376,141 Notic…
  12. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …ll insurance companies is estimated as: [259,230 × (358 entities × 73.1% SBA small entities)] ≉ 189,428 retrospective reviews. Back to Citation 854.  This burden is estimated as: (189,428 reviews by small entities × 1 hour) ≉ 189,428 hours. A labor rate of $165.71 is used for a legal professional. The labor rate is app…
  13. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  14. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    erest) on the dates shown was as follows: Bate Balance 8/31/78 $123,727.08 8/31/79 131,211.18 8/31/80 141,708.07 8/31/81 144,502.33 4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
  15. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  16. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  17. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  18. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …oan. Ex. C32. On August 26, 1987, Respondents rolled over the proceeds of CD No. 350, totaling $173,428.64, into CD No. 11813-17493 issued by TC.9 Ex. C23; Respondent's Response to Complainant's Interrogatory No. 34 at 10. Thereafter, on October 13, 1987, CD No. 346 matured, and Respondents rolled over its proceeds, in…
  19. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  20. 67 T.C. 167 — Quality Brands, Inc. v. Commissioner
    IRCCourt RulingsNov 8, 1976related by meaning
    n changing its name. Decision will be entered for the respondent in docket No. 6797-74. Decision will be entered under Rule 155 in docket No. 6798-74. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue. Mr. Hebert is excluded from the computation because his salary …